Warning: Signs Point To Risky Landfill Business

Mark A. Taylor and Jeffrey L. Joyce

Keeping up with the Occupational Safety and Health Administration's changing rules governing risks to landfill operators would require a fulltime safety officer. If that's not an option, following commonsense safety tips can help make your facility virtually accident-proof and ensure that your employees stay healthy and your customers return.

Most occupational accidents occur due to carelessness or lack of attentiveness. Operators can improve on-the-job safety by increasing their knowledge of safety issues, regulations and personal protective equipment (PPE). In fact, employee right-to-know laws require employers to provide training and information about safety issues that are inherent to a given occupation.

Nearly every aspect of landfill operations call for activities that are regulated under different categories of occupational safety such as confined space entry; excavation and trench safety; and hazardous waste worker health and safety. Subtitle D requires that specific written plans be established for each of these areas. However, many safety plans for emergency response, fire control, gas management, confined space entry, hazardous and liquid waste screening need to be updated.

Safety meetings should be conducted regularly to review plans and procedures as well as new safety protocols, operations and equipment.

PPE is necessary for even the most rudimentary tasks at a municipal solid waste landfill. Work clothing should include hard hats, leather gloves and protective footwear. In addition to steel toes, footwear should include slip-resistant treads and a steel mid-sole to protect against puncture injuries. Keep exposed skin to a minimum, especially for personnel who come in contact with waste or leachate.

Though frequently ignored, safety glasses, hearing protection and dust masks can significantly reduce the risk of eye injury, gradual hearing loss and respiratory illness. Some assignments may require more rigorous forms of PPE such as chemical-resistant gloves, boots and clothing, cartridge-type respirators, self-contained breathing apparatuses, monitoring devices, safety harnesses and ropes.

The majority of jobs in a landfill environment - and the most dangerous types of operations - are performed around heavy equipment. Most accidents occur when equipment operators and ground personnel don't follow basic safety procedures, including:

* Check to make sure the machinery is in proper operating order. Inspect all safety equipment such as backup alarms, rollover protection, seat belts, hydraulics, steering and brakes to ensure that they function properly. Never operate a piece of equipment that needs repair.

* Check the work area before operating machinery. If you're not sure the area is clear, get down and look first; a quick check could save a life.

* Be aware of the location and direction of moving equipment. Never assume that an operator sees you. Ground personnel should maintain a safe distance; equipment can lose its footing, especially near slopes and trenches or on wet ground.

* Constantly watch landfill users. The ordinary citizen bringing waste to the working face is not aware of the potential dangers of heavy equipment. Even frequent users aren't always conscious of moving equipment and personnel.

* Never allow passengers on moving equipment. Cabs are typically designed for only one person.

* Don't assume that any piece of equipment isn't dangerous when it's not moving. Carefully mount and dismount; check to make sure that all steps and handholds are properly attached and functional; remove mud, oil or grease from steps and handholds; and never jump from the equipment.

* Be sure that all safety shields, guards and lockouts are in position and functioning before servicing equipment. Remove the keys and flip the seat up or leave a sign to let the operators know that the equipment is being replaced.

* Try not to work around or under a raised bucket or blade until you are properly protected.

Equipment operators should always be aware of potentially dangerous ground conditions. Numerous fatalities have occurred while grading unstable slopes or excavating borrow areas. Never undermine slopes or create "highwalls" (vertical cuts) while excavating borrow areas. Excavate soils from the top to the bottom of a cut slope, leaving a stable slope as the work progresses. Create benches if necessary to provide stable cut slopes. A geotechnical engineer should be consulted for site-specific recommendations.

When operating equipment on fill slopes, proceed slowly until the slope is proven stable. Soft areas are common in waste fill slopes and can cause sudden drops or slippage when equipment passes. The operator must know the limits of the equipment, the ground conditions and his or her own ability to operate a piece of equipment safely.

Waste Screening Landfill operators are now required to screen incoming wastes for hazardous, PCB-laden and/ or liquid wastes to prevent their disposal in landfills. Federal "landbanned" wastes, free liquids and sludges that fail the paint filter test and hazardous wastes regulated under Subtitle C are prohibited; most states impose additional restrictions. If hazardous wastes are discovered after a load is accepted, the owner/ operator is required to store it and arrange for proper disposal under stringent EPA and DOT regulations - which is much more complicated than it may sound.

Since there has been little guidance on this requirement, many states are struggling to define an acceptable screening program. A sampling frequency of 1 percent of incoming waste has been discussed, but operators are confused about whether this means 1 percent of incoming loads or 1 percent measured by volume or weight.

Develop a specific waste screening plan for each facility to designate minimum inspection frequency, approved screening areas, waste identification guidelines, methods to assure random screening, inspection procedures, containment requirements during inspection, decontamination procedures, health and safety training requirements and procedures for the disposition of hazardous or other problematic wastes.

Ensuring the personal safety of the staff members who screen the waste involves health and safety training, PPE, air monitoring and medical monitoring. Health and safety training (such as the OSHA 40-hour HAZWOPER course) and medical monitoring can be worth the cost. Problem wastes may not be containerized and may be poorly labelled or intentionally disguised. When a problem waste is identified, avoid excessive exposure and/or accidental releases.

To minimize the possibility of fires, examine each incoming waste load for flames, smoke or odor. Fire extinguishers should be located on each piece of equipment and in the landfill office and maintenance buildings. Fire extinguishers are adequate for small, localized fires. A stockpile of at least 15 cubic yards of soil should be maintained near the working face for extinguishing small surface fires that are too large to control with fire extinguishers.

The local fire marshal should be called immediately when fire extinguishers or soil do not suffice or when a subsurface fire is suspected. Emergency response and safety plans should be filed with the fire department and emergency medical service so that they are familiar with the landfill site and emergency procedures. Each agency should have a key to the access gate in case an incident occurs when the landfill is closed. Sedimentation ponds can serve as emergency reservoirs that local firefighters can use to extinguish large fires.

If a fire occurs among waste in the disposal area, the waste should be removed if possible. If a subsurface fire occurs in the fill, it should be dug out and spread on bare ground so that firefighters can spray water on the excavation equipment and extinguish the burning waste. Equipment operators should wear respirators and beware of shifting waste and other hazards.

Landfill gas should be monitored during the active life of the landfill and during the postclosure care period. At a minimum, gas detection probes and buildings located within 1,000 feet of the waste boundary should be monitored quarterly for explosive gases.

If the gas exceeds lower explosive limit (LEL) levels, take immediate action to protect personnel and the public from potentially explosive conditions: immediately evacuate all personnel from the area, remove ignition sources and vent structures. If an exceedence occurs at the property boundary, houses in the direction of the migrating gas should be tested for explosion hazards.

Use monitoring action levels of onehalf the regulatory levels or less. If gas readings exceed those levels, increase the monitoring frequency to weekly until four consecutive readings are below those levels.

Controlling Access Subtitle D regulations require that landfills be fenced to prevent the general public, scavengers and vandals from entering the site for any unauthorized purposes.

It is common to separate private citizens from commercial users by providing convenience centers or drop-off boxes outside the landfill gate or between the gate and the landfill scales. Some-times private citizens are directed to a separate working face on the landfill.

Customer safety at the working face is a major concern due to the amount of activity going on and heavy equipment moving around. A spotter at the working face can direct traffic, since backing is common and the area tends to be congested. The spotter can also serve as a waste screener for the loads that are not selected for thorough inspection.

Using traffic control and routing to keep customers away from landfill operations is a critical safety issue. Whenever possible, try to build separate roads for landfill equipment to use. Too often, heavy earth-moving equipment such as scrapers or "pans" have inadequate brakes and are poorly equipped to signal or otherwise avert potential accidents. Ongoing construction also tends to increase the mixed traffic problems.

Roads for landfill customers should be in good repair and wide enough to reduce the potential for collisions. Keep the road between the scale and the working face as short as possible with a minimum sight distance of 150 feet at all times and a speed limit of 10 to 15 mph. One way to catch people's attention is to set the speed limit at odd numbers, such as 13 mph.

Don't establish passing zones where sight distances are limited or at intersections since small vehicles may be tempted to pass the heavy trucks. Keep the site's intersections and points of convergence to a minimum.

Good signage is essential to communicate directions, landfill rules and safety guidelines to the landfill customers. Clear, concise messages with large letters and directional arrows are important. Some landfill operators even suggest printing multi-lingual messages or using readily identifiable pictures for users who don't speak English. Don't clutter a sign with information that can't easily be read from aboard a moving vehicle.

Modern landfills are much safer facilities than they were 25 years ago, but the landfill environment, by nature, still poses numerous risks to health and safety. Landfill operators have to take responsibility for the safety of their employees and the public by safeguarding the hidden dangers as well as the obvious ones.